49(1)Section 804B (insurance companies carrying on more than one category of business: restriction of credit) is amended as follows.U.K.
(2)In subsection (1)(a), after “category of” insert “ long-term ”.
(3)In subsection (2), omit “or section 438B”.
(4)For subsection (3) substitute—
“(3)Where the relevant income arises from an asset which is linked solely to a category of business, the whole of the foreign tax is attributable to that category of business, unless the case is one where subsection (7) below applies.
(3A)Where the relevant income arises from foreign currency assets, the whole of the foreign tax is attributable to gross roll-up business, unless the case is one where subsection (7) below applies.”
(5)In subsection (4)—
(a)for “long-term business which is not life assurance” substitute “ PHI ”, and
(b)omit “or 438B”.
(6)In subsection (5), for the words following “is” substitute “ gross roll-up business. ”
(7)In subsection (6)—
(a)omit “or 432D” (in both places), and
(b)for “the category of business in question” and “that category” substitute “ gross roll-up business ”.
(8)In subsection (7), for—
(a)“the category of business in question”, and
(b)“that category”,
substitute “ gross roll-up business ”.
(9)For subsection (9) substitute—
“(9)Where for the purposes of this section an amount of foreign tax is attributable to gross roll-up business, credit in respect of the foreign tax so attributable shall be allowed only against corporation tax in respect of profits chargeable under section 436A.”